Ask a converting hall manager what ISO 22002-4:2025 adds and you will usually hear “hygiene, same as everyone else”. Then walk the line. There is a snap-off knife on the reel stand, a pallet of unprinted board under a stack of printed reels, and a rework bin with no rule about what goes into what. Three findings in four minutes, and none of them appear in ISO 22002-100.
In short
- Set-off is defined in ISO 22002-4:2025 as transfer of substances from one surface to the food contact surface through direct contact caused by stacking or reeling. Section 12.2 makes it your problem if you print or coat.
- Migration under section 12.4 reaches beyond your own product to the pallets, films and containers used around it.
- Snap-off blade knives are forbidden by section 12.3, alongside a formal sharps procedure.
- Rework under section 17 requires the acceptable quantity, type, conditions and method of addition to be specified, with records proving regulatory and customer conformance is maintained.
- The FSSC 22000 Version 7 for Food and Feed Packaging Manufacturing course (R2 950) works through all of it clause by clause at category I scope.
Set-off: the hazard that travels in the reel
Set-off is the one requirement that makes converters stop and reread. ISO 22002-4:2025 defines it at section 3.4 as the transfer of substances from one surface of a material to the food contact surface through direct contact caused by stacking or reeling. In plain terms: ink, lacquer or coating from the outside of the web reaches the inside of the next wrap while the reel sits in the warehouse.
Section 12.2 requires printed and coated materials to be controlled to the level defined by hazard analysis. Note what that does and does not say. It does not hand you a limit. It requires you to have analysed the hazard for your own inks, substrates, cure conditions and storage times, and to control to what that analysis concluded. A converter who has adopted a supplier’s declaration without doing the analysis has the evidence trail the wrong way round, and an auditor will ask for the analysis first.
The practical evidence is a hazard analysis that names set-off explicitly, ink and coating specifications with any migration or set-off data the supplier holds, cure or dry verification where it applies, and storage conditions and times for printed reels.
Migration: the clause that reaches past your own product
Section 12.4 requires controls where there is a potential food safety hazard from migration or another transfer mechanism. Most converters expect that and have specifications to prove it.
The part that surprises people is the second half. Packaging used around the packaging you make, meaning pallets, films and containers, shall be made of suitable material, shall be clean, and shall not contaminate the food packaging being produced. Your finished goods stretch wrap and your pallets are in scope of the clause. A note in the standard observes that chemical treatment of pallets can be necessary to meet regulatory or customer requirements, which is an observation rather than an instruction to treat them; if you do treat them, that becomes a chemical you have to control.
Sharps: the shortest clause with the fastest finding
Section 12.3 requires a formal procedure for the use of sharps, requires that no sharp objects or loose tools be left in any place or on surfaces where product contamination can occur, and states that the use of snap-off blade knives shall be forbidden.
Snap-off knives exist in every converting hall because they are cheap and convenient, and the blade segment that snaps off is exactly the foreign body the clause is written against. Replacing them with retractable safety knives on a controlled issue is a week of work and closes the finding permanently. Doing it before the audit rather than after is worth more than it costs, because a sharps finding invites the auditor to look harder at your whole foreign matter programme.
Rework: specify it before the shift decides
Section 17 on rework usage requires the acceptable quantity, type and conditions of rework use to be specified, the method of addition to be defined, measures to prevent contamination with materials not intended for food contact, and documented information retained to demonstrate that conformance to regulatory and customer requirements is maintained.
The phrase to hold on to is materials not intended for food contact. In a converting hall the rework stream is where non-food-contact printed waste, edge trim and start-up waste can quietly rejoin a food contact product. Rework that came back from the same customer order carries no exemption, and neither does rework that looks identical to the good product.
The defensible position most strong converters take is to name each rework stream and its permitted destination with an inclusion limit, and to prohibit the streams that cannot be controlled. Prohibition is easy to audit and easy to train.
Where these four sit against the scheme requirements
All four belong to ISO 22002-4:2025 rather than to the FSSC additional requirements, but they connect to them. Set-off and migration feed the hazard analysis that clause 2.5.11 then builds on, and item a) of that clause applies to category I where packaging imparts a functional effect on food such as shelf life extension. Rework feeds traceability. Sharps feeds the foreign matter management requirements at clause 2.5.11 d), which require a risk assessment determining the need and type of detection equipment, a documented procedure for the equipment selected, and procedures for managing all breakages linked to potential physical contamination.
Reading them as one system rather than four separate clauses is what the packaging course is built to do, and it is what shortens the audit.
Common questions
What exactly is set-off?
Transfer of substances from one surface of a material to the food contact surface through direct contact caused by stacking or reeling, as defined at section 3.4 of ISO 22002-4:2025. Section 12.2 requires printed and coated materials to be controlled to the level defined by hazard analysis.
Does ISO 22002-4 set a migration limit?
No. It requires controls where there is a potential food safety hazard due to migration or another transfer mechanism. The limits come from the regulation of the market you supply and from your customer specification, and your job is to show the controls hold against them.
Can we use snap-off knives if we control them?
No. Section 12.3 states that their use shall be forbidden. It is one of very few absolute prohibitions anywhere in the ISO 22002 family.
Do the pallets we ship on really fall under the standard?
Yes. Section 12.4 states that packaging such as pallets, films and containers shall be made of suitable material, shall be clean and shall not contaminate the food packaging being produced.
How is the course assessed?
Self-paced, with a knowledge check at the end of each teaching module and a final assessment marked by the platform. Every question carries a written explanation naming the clause that settles it, so a wrong answer teaches you something. The Packaging Pathway Bundle takes the three course pathway to R4 950.